Effective Date: July 22, 2020
Please note that this Policy does not apply to information collected through means other than the Site. Personal information collected in connection with Pine Brook’s investment fund management business activities and services (collectively, the “Services”) is governed by a separate privacy notice and applicable agreements, as required by applicable law.
Agreement to the Policy
By using the Site, you consent to this Policy and to the use and disclosure of information about you in accordance with the data practices described in this Policy.
Pine Brook may modify the Policy at any time to reflect updates to its data practices or the law, so please review it periodically. If we make changes to the Policy, we will post the updated Policy to this site reflecting these changes and indicate at the top of the Policy the date it was updated, unless additional notice is appropriate or required by law. Any revisions to the Policy become effective when we post the revised Policy on the Site. Your use of the Site following these revisions means that you accept the updated Policy.
What Information We Collect
Pine Brook collects the following types of information, some of which may, alone or in combination with other information we have, identifies or relates to you (“personal information”):
- Location information, including location information either provided by a device interacting with the Site or associated with your IP address; and
- Technical information we automatically collect when you visit the Site, including your device identifier or IP address, the type of browser and device you are using, and information about your device’s operating system. (For more information on our collection of technical information, see the “Cookies and Similar Technologies” section below.)
Purposes for Which We Collect and Use Your Information
Pine Brook may use the information we collect in a variety of ways to enhance your experience while using the Site and Services, including:
- Monitor metrics such as total number of visitors, traffic, and demographic patterns;
- Provide, improve, test, and monitor the effectiveness of the Site;
- Improve customer services and Pine Brook products and offerings;
- Respond to your questions;
- Communicate with you regarding our protected content, such as annual meeting content and videos, as well as to provide you with information about additional products and services you may be interested in;
- Monitor and ensure Site integrity and security; and
Cookies and Similar Technologies
Pine Brook does not collect personal information about an individual’s online activities over time and across third-party web sites or online services, other than as described in this Policy.
You can control whether your computer or device will allow cookies. To do so, consult your browser settings, which generally can be found in the “help” section on the browser toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Please note that if you set your browser to disable cookies or other technologies, you may not be able to access certain parts of the Site or parts of the Site may not work properly.
Third Party Tracking and “Do Not Track” Signals
Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Policy to describe how we do so.
Sharing Your Information
In certain circumstances we may share your personal information with unaffiliated entities without further notice to you, unless required by the law, as set forth below:
- Vendors and Service Providers: To assist us in providing the Site, meeting business operation’s needs, and performing certain services and functions, we may share personal information with vendors and service providers, including providers of hosting services, cloud services, and other information technology service providers; email communication software and email newsletter services; advertising and marketing services; customer relationship management and customer support services; and web analytics services. Pursuant to our instructions, these parties will access, process, or store personal information in the course of performing their duties to us.
- Affiliates: We may disclose personal information collected from the Site to our affiliates, meaning an entity that controls, is controlled by, or is under common control with us, in order to communicate with you, provide the Services, or achieve any other purpose described in this Policy. Our affiliates may use the personal information we share in a manner consistent with this Policy.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
Data Integrity and Security
We use commercially reasonable safeguards to help keep the information collected through the Site secure. However, no information security safeguards can be guaranteed to be completely secure. As a result, Pine Brook cannot ensure or warrant the security of any information you transmit to us, or guarantee that your information on the Site may not be accessed, disclosed, altered, or destroyed while in transmission to or in storage with Pine Brook.
Links to Third-Party Websites
Pine Brook does not knowingly collect or solicit personal information from any persons under the age of 16 or knowingly allow such persons to register for the Site. The Site and its content are not designed for or intentionally directed to children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal information to us through the Site please contact us using the information below and we will endeavor to delete that information from our databases.
This Site is intended for use in the United States. If using the Site from outside the United States, you understand and acknowledge that your personal information will be transferred from your location to our facilities and servers in the United States.
Additional Information For California Residents
In accordance with the California Consumer Privacy Act (“CCPA”), this section is intended to inform California residents of (1) the personal information that we collect and how we disclose that information, and (2) the privacy rights California residents may have relating to their personal information and how those rights can be exercised.
Personal Information Collection and Disclosure
- Categories of Personal Information Collected: In the past 12 months, we have collected the following categories of personal information, as described in greater detail in the “What Information We Collect” section above:
- Location Information provided by a device interacting with the Site or associated with your IP address.
- Online Activity Information, such as your device identifier or IP address, the type of browser and device you are using, and information about your device’s operating system. (For more information on our collection of technical information, see the “Cookies and Similar Technologies” section above.)
- Sources of Personal Information: We collect the above categories of personal information from you, our service providers, and as otherwise described in the “What Information We Collect” section above.
- Purposes of Collection and Disclosure: We collect and disclose the above categories of personal information for the business and commercial purposes described in the “Purposes for Which We Collect and Use Your Information” and “Sharing Your Information” sections above.
- Categories of Personal Information Disclosed for a Business Purpose: In the past 12 months, we have disclosed for a business purpose all of the above categories of personal information to service providers and as described in the “Sharing Your Information” section above.
- Categories of Personal Information Sold: We have not sold any of the above categories of personal information in the past 12 months.
California Privacy Rights
To the extent provided for by the CCPA and subject to applicable exceptions and exclusions, California residents have the following privacy rights in relation to the personal information we collect:
- The right to know what personal information we have collected and how we have used and disclosed that personal information.
- The right to request deletion of your personal information.
- The right to opt out of the sale of your personal information.
- The right to be free from discrimination for the exercise of any of your privacy rights.
Exercising Your Rights: California residents can exercise the above privacy rights by calling 212-847-4333, or emailing us at email@example.com
Verification: In order to protect your personal information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a request to know or delete personal information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional personal information for verification. If we cannot verify your identity, we will not provide or delete your personal information.
Authorized Agents: You may submit a request to know or a request to delete your personal information through an authorized agent. If you do so, we may require the agent to present signed written permission to act on your behalf and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
For any questions, comments or concerns, or if you would like to view this Policy in an alternative format, please contact us at Pine Brook at firstname.lastname@example.org or at 212-847-4333.